Mandatory payment timeline under Sabka Vishwas scheme cannot be extended by judicial order; earlier extension was recalled.

Relief under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 was governed by the mandatory statutory timeline for payment, requiring the declarant to pay in the prescribed manner and on or before the date shown in Form SVLDRS-4. The earlier order extending time was unsustainable because it overlooked Section 127(5) of the Finance Act, 2019 and Rule 7 of the Scheme, which fixed the mode and time of payment. The earlier order was recalled and no relief was granted.

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Issues: Whether the earlier order extending time for payment under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 could stand in view of the mandatory requirement to pay the amount within the time prescribed under the scheme.

Analysis: Section 127(5) of the Finance Act, 2019 required payment in the manner directed by the designated committee, and Rule 7 of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 required the declarant to pay electronically the amount indicated in Form SVLDRS-4 on or before the prescribed date. These provisions were not taken into account in the earlier order granting extension of time.

Conclusion: The earlier order was recalled and the writ petition was dismissed.

Final Conclusion: Relief under the scheme was held to be governed by the mandatory statutory timeline, and the petitioner obtained no relief.

Ratio Decidendi: Where a tax settlement scheme prescribes a mandatory mode and time for payment, the court cannot extend that statutory deadline by judicial order.

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